FEDERAL REAL 

PROPERTY

Actions Needed to 

Improve How 

Agencies Manage 

Structures

Report to Congressional Requesters

January 2014

GAO-14-87

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-87, a report to 

congressional requesters

January 2014

FEDERAL REAL PROPERTY

ACTIONS NEEDED TO IMPROVE HOW AGENCIES 

MANAGE STRUCTURES

Why GAO Did This Study

The federal government’s real property 

portfolio includes land, buildings, and

structures. GAO has designated the 

management of federal real property 

as high-risk based largely on the 

management of federal buildings. 

However, over half of the assets are 

structures, such as roads, dams, and 

radio towers. GAO was asked to 

examine management issues related

to structures. This report examines (1) 

the scale and scope of federally owned 

or leased structures, (2) how federal 

agencies track and categorize federal 

structures, and (3) the extent to which 

the challenges federal agencies face in 

managing buildings also apply to 

structures. GAO analyzed FRPP data 

on structures managed by federal 

civilian agencies against federal 

internal control standards for executive 

branch agencies and OMB guidelines,

visited 24 sites selected to represent a 

variety of structure types from five 

civilian federal agencies with high 

numbers of structures, and interviewed 

officials from the five agencies, OMB 

and GSA about FRPP data collection

and how agencies manage their 

structures. 

What GAO Recommends

GAO recommends that OMB, in 

coordination with the FRPC, develop 

guidance to improve agencies internal 

controls to produce consistent, 

accurate and reliable information on 

their structures. GSA, in coordination

with the FRPC, should clarify the 

definition of structures and assess the 

feasibility of limiting the data collected 

on structures submitted to the FRPP. 

OMB and GSA agreed with the 

recommendations, and GSA provided 

an action plan to implement GAO’s 

recommendations.

What GAO Found

In 2012, federal agencies reported to the Federal Real Property Council 

(FRPC)—an organization comprised of all real property holding federal 

agencies—that they are responsible for operating over 480,000 federally owned 

structures. Information about these structures is recorded in the FRPC’s Federal 

Real Property Profile (FRPP), the government’s comprehensive database that 

describes the nature, use, and extent of federal real property. About 176,000 of 

those structures are operated by civilian federal agencies. The federal 

government manages a wide variety of structures. Some of these are common 

across agencies, such as roads and parking structures, while some are more 

specific to agencies’ missions, such as historic structures or particle accelerators. 

Agencies take different approaches to defining and inventorying structures 

making the aggregation of data in the FRPP’s database unreliable. Agencies we 

reviewed defined structures differently leading to inconsistencies in what assets 

are included in the FRPP, including counting some building-like facilities as 

structures. We also found that these agencies counted structures differently, 

provided inaccurate structure location information, and categorized their 

structures inconsistently, all of which limits the usefulness of the data on 

structures in the FRPP. Additionally, the agencies we reviewed submitted 

incorrect information for key data elements, such as the replacement value, 

annual operating costs, and condition. GSA officials who manage the FRPP said 

that FRPC chose to provide flexibility in the reporting guidance for data on 

structures to account for the wide diversity in federal structures, but it also 

aggregates the data as if they were comparable. Even if this data were useful, 

FRPC reports very little information on structures, and officials at GSA told us 

that there is low interest in and demand for this information, creating few 

incentives to improve data reliability. In prior reports, we have stressed the 

importance of limiting the number of elements to the vital few that are considered 

essential for producing data for decision making in light of the costs in collecting 

this data. 

Agencies generally face similar challenges in managing structures as they do in 

managing buildings. Officials from all of the selected agencies stated that most 

challenges centered on prioritizing resources to maintain structures, disposing of 

excess structures, and ensuring their safety and security.

Examples of Structures Owned by the Federal Government

View GAO-14-87. For more information, 

contact David Wise at (202) 512-2834 or 

wised@gao.gov.
Page i GAO-14-87 Federal Real Property

Letter 1

Background 3

Agencies Operate a Wide Variety of Structures, Including 

Structures Specific to Their Missions 5

Inconsistent Approaches to Tracking Structures and Inaccurate 

Information May Undermine the Reliability of Nationwide Data 

on Structures 9

Agencies Face Similar Challenges in Maintaining, Securing, and 

Disposing of Structures as They Do for Buildings 27

Conclusions 31

Recommendations for Executive Action 31

Agency Comments 32

Appendix I Objectives, Scope, and Methodology 34

Appendix II Comments from the General Services Administration 38

Appendix III Full Text for Figure 3 on How Agencies Aggregate and Disaggregate 

Structures in FRPP 40

Appendix IV GAO Contact and Staff Acknowledgments 42

Tables

Table 1: Federal Civilian Agency Structures by FRPP Real 

Property Use Type 6

Table 2: Selected Agencies Definitions of Structures 10

Figures

Figure 1: Examples of Mission-Related Federal Structures 8

Figure 2: Examples of Building-Like Structures 11

Figure 3: Example of How Agency Officials Aggregate and 

Disaggregate Structures in FRPP 13

Figure 4: Examples of Similar Structures with Different Purposes 17

Contents
Page ii GAO-14-87 Federal Real Property

Figure 5: Examples of Inconsistent and Inaccurate Replacement 

Values for Structures 20

Figure 6: Example of Zero Annual Operating Costs for a Structure, 

a Committal Shelter at Quantico (VA) National Cemetery, 

Virginia 22

Figure 7: Examples of the Condition of Interior’s Fish and Wildlife 

Service’s Historic Cannery at Don Edwards San 

Francisco National Wildlife Refuge in California 25

Figure 8: Structures That Likely Have Little Private-Sector Value 26

Figure 9: Examples of Security and Safety Challenges Presented 

by the Long Length of and the Swiftly Flowing Water in 

the Delta-Mendota Canal in California 29

Figure 10: Unused Water Tower at USDA’s Beltsville Facility, 

Maryland 30

Abbreviations

ARS Agricultural Research Service

BARC Beltsville Agricultural Research Center

BLM Bureau of Land Management

BOR Bureau of Reclamation

DOE Department of Energy

DOT Department of Transportation

FAA Federal Aviation Administration

FRPC Federal Real Property Council

FRPP Federal Real Property Profile

FWS Fish and Wildlife Service

GSA General Services Administration

NPS National Park Service

OMB Office of Management and Budget

USDA Department of Agriculture

VA Department of Veterans Affairs

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

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Page 1 GAO-14-87 Federal Real Property

441 G St. N.W.

Washington, DC 20548

January 6, 2014

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn, M.D.

Ranking Member

Committee on Homeland Security and Government Affairs

United States Senate

The Honorable Claire McCaskill

Chairman

Subcommittee on Financial and Contracting Oversight

Committee on Homeland Security and Government Affairs

United States Senate

Federal real property management has been on our high-risk list since 

2003 due to overreliance on leasing, the presence of unneeded and 

underutilized facilities, and security challenges at federal facilities.1

You asked us to review issues related to how federal agencies manage 

structures. This report examines: (1) the scale and scope of federallyowned or leased structures, (2) how federal agencies track and 

categorize federal structures, and (3) the extent to which the challenges 

federal agencies face in managing buildings also apply to structures.

Federal agencies have reported to the Federal Real Property Council 

(FRPC)—an organization comprised of all real property holding 

departments and agencies subject to the Chief Financial Officers Act of 

1990—that they are responsible for operating over 480,000 federallyowned structures, such as roads and bridges, railroads, utility systems, 

weapons ranges, and monuments and memorials. Although structures 

account for more than half of all reported federal real property assets, 

FRPC’s attention, including our work, has focused on the management of 

buildings more than structures. This may be due to the costs of housing 

and protecting federal workers in federal buildings and the potential 

private sector value of unneeded buildings.

 1

GAO, High Risk Series: An Update, GAO-13-283 (Washington, D.C.: February 2013).
Page 2 GAO-14-87 Federal Real Property

To address these objectives, we reviewed pertinent laws, regulations, 

policies, and other documents related to federal real property 

management. We reviewed guidance from the FRPC regarding 

structures, including the Guidance for Real Property Inventory Reporting 

for the Federal Real Property Profile (FRPP)—the government-wide 

database of real property holdings. We obtained FRPP summary data 

from fiscal year 2012, the most recent data available, for structures 

owned and operated by the federal government. We selected five 

agencies for more in-depth review: the Department of Agriculture (USDA), 

the Department of Energy (DOE), the Department of the Interior (Interior), 

the Department of Transportation (DOT), and the Department of Veterans 

Affairs (VA).2

We conducted this performance audit from January 2013 to January 2014 

in accordance with generally accepted government auditing standards. 

According to FRPP data, these five agencies were 

responsible for 83 percent of the federal structures among federal civilian 

agencies. For each of these agencies, we reviewed agency-specific 

policies, guidance, and other documents related to structures and 

conducted interviews with agency officials about how they manage 

structures. We also analyzed information submitted to the fiscal year 

2012 version of the FRPP for each of the selected agencies. Using the 

most recent FRPP submissions we had at the time for each agency, we 

selected a non-probability sample of sites and conducted four site visits 

(Los Angeles and San Francisco, California; Chicago, Illinois; and 

Washington, D.C.). During our site visits, we viewed structures at 24 

locations for our five selected agencies. We selected these sites and 

locations to obtain a variety of locations for our selected agencies and

discuss management issues related to different types of structures. We 

selected a variety of structures from each agency’s FRPP submission 

using factors such as the structure’s type, replacement value, operating 

costs, and condition. We compared the FRPP data for those structures 

with the agency’s real-property tracking systems and with observations of 

the actual structure. We also interviewed local agency officials at each 

site. Our findings based on our examination of the selected agencies and 

sites are illustrative and do not support generalizations about other 

federal agencies or properties. See appendix I for more detailed 

information on our scope and methodology.

 2

While we have recently reported on the quality of the data in FRPP, we have determined 

that the FRPP data can be used for case study site selection. (See app. I for more detail.) 
Page 3 GAO-14-87 Federal Real Property

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

In 2004, the President issued Executive Order 13327 establishing the 

FRPC, composed of senior federal real property managers, and 

representatives from the Office of Management and Budget (OMB) and 

the General Services Administration (GSA), among others.3

Agencies are required to annually submit 23 separate data elements to 

FRPP for all of their structures. The data elements include basic inventory 

data (type, use, size, and location) and other elements (condition, 

replacement value, operating costs, congressional district, and historical 

status). Some of the FRPP data elements differ for structures as 

compared with the data for buildings or land. For example, for measures 

of size, which are standard square feet for buildings or acres for land, 

agencies should report a unit of measure based on the type of structure 

(such as linear feet for canals or lane miles or square yards for roads and 

bridges). The FRPC also made some changes to the fiscal year 2013 

FRPP guidance related to how agencies collect and report data for 

structures. For example, the FRPP will no longer contain information on 

The 

executive order required FRPC to work with GSA to establish and 

maintain a single, comprehensive database describing the nature, use, 

and extent of all real property under the custody and control of executive 

branch agencies, except when otherwise required for reasons of national 

security. To meet this requirement, GSA in coordination with FRPC 

established the FRPP and provides guidance to agencies about how to 

annually report real property under the custody and control of executive 

branch agencies in three categories: land, buildings, and structures.

 3

Federal Real Property Asset Management, Exec. Order No. 13327, 69 Fed. Reg. 5897 

(Feb. 6, 2004). The executive order applies to executive branch agencies listed at 31 

U.S.C. §901(b); the Departments of Agriculture, Commerce, Defense, Education, Energy, 

Health and Human Services, Homeland Security, Housing and Urban Development, the 

Interior, Justice, Labor, State, Transportation, the Treasury, and Veterans Affairs; the 

Environmental Protection Agency; the National Aeronautics and Space Administration; the 

U.S. Agency for International Development; GSA; the National Science Foundation; the 

Nuclear Regulatory Commission; the Office of Personnel Management; the Small 

Business Administration; and the Social Security Administration. 

Background
Page 4 GAO-14-87 Federal Real Property

mission dependency, will add a new field for repair needs, and will 

automatically calculate the condition index using the replacement value 

field and the newly created repair needs field.

As we stated in the 2013 update to the High-Risk Series, although some 

progress has been made in obtaining data about federal real property, the 

government still continues to lack consistent, accurate, and useful data 

that could support strategic decision-making about federal real property.4

Internal control standards for federal executive branch agencies require 

that agencies have relevant, reliable, and timely information for decisionmaking and external-reporting purposes.5 OMB guidelines state that 

agencies should develop detailed guidance necessary for producing 

quality data. Among other things, OMB’s definition of quality ensures that 

accurate, reliable, and unbiased information is presented in an accurate, 

clear, complete, and unbiased manner. These guidelines state that 

agencies should treat information quality as integral to every step in the 

creation of that information, from creation, collection, maintenance, and 

dissemination.6 We have also found that consistency means that the data 

are sufficiently clear and well-defined to yield similar results in similar 

situations.7 The Government Accountability and Transparency Board, 

established in 2011 to provide strategic direction for enhancing 

transparency of federal spending data, found that lack of consistent data 

creates obstacles to transparency and accountability. In addition, it 

determined that consistent data promote more accurate and comparable 

data for improved reporting and decision-making.8

 4

However, we also 

found in 2012 that collecting and analyzing data creates costs for federal 

agencies as they must direct time and staff resources to this task and 

emphasized the importance of limiting the number of measures to the 

GAO-13-283.

5

See, e.g., 31 U.S.C. 3512 (c), (d) (commonly referred to as the Federal Managers’ 

Financial Integrity Act (FMFIA)) and GAO, Standards for Internal Control in the Federal 

Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). 

6

Office of Management and Budget, Guidelines for Ensuring and Maximizing the Quality, 

Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies; Notice; 

Republication (Washington, D.C.: Feb. 22, 2002).

7

GAO, Assessing the Reliability of Computer-Processed Data, GAO-09-680G

(Washington, D.C.: July 2009). 

8

Government Accountability and Transparency Board, Report and Recommendations to 

the President December 2011 (Washington, D.C., December 2011).
Page 5 GAO-14-87 Federal Real Property

vital few measures considered essential for producing data for decisionmaking.9

In the fiscal year 2012 FRPP, federal agencies reported that they were 

responsible for over 480,000 structures. Of the nearly 176,000 structures 

that federal civilian agencies were responsible for, about 98 percent were 

owned by the federal government and about 2 percent were leased.10 The 

five agencies we selected for our review were responsible for 83 percent 

of civilian federal structures. The FRPP categorizes structures into 22 

different types. The most commonly reported type was roads and bridges 

followed by recreational structures, which include outdoor recreational 

structures such as athletic fields and courts, stadiums, golf courses, and 

ski slopes.11 Table 1 provides FRPP summary level information about 

structures as reported by federal civilian agencies.

 9

GAO, Federal Real Property: National Strategy and Better Data Needed to Improve 

Management of Excess and Underutilized Property, GAO-12-645 (Washington, D.C.: June 

20, 2012). 

10The FRPP separates structures into other “owned” categories such as: Foreign 

Government Owned, State Government Owned and Museum Trust. The numbers of 

structures in these categories (453) were less than 1 percent of total structures.

11FRPP real property use type categories, such as Recreational (other than buildings), 

include brief descriptions of what they should entail but do not include subcategories to 

further identify the types of recreational structures that the federal government owns.

Agencies Operate a 

Wide Variety of 

Structures, Including

Structures Specific to 

Their Missions
Page 6 GAO-14-87 Federal Real Property

Table 1: Federal Civilian Agency Structures by FRPP Real Property Use Type 

FRPP real property use typea Total structures Percentage of total Cumulative percentage

Roads and Bridges 29,392 16.7% 16.7%

Recreational (other than buildings) 25,162 14.3% 31.0%

Navigation and Traffic Aids (other than buildings) 22,608 12.8% 43.9%

Utility Systems 18,963 10.8% 54.6%

Parking Structures 16,799 9.5% 64.2%

Reclamation and Irrigation 10,602 6.0% 70.2%

Communications Systems 8,509 4.8% 75.0%

Storage (other than buildings) 6,774 3.8% 78.9%

Harbors and Ports 2,751 1.6% 80.4%

Flood Control and Navigation 2,738 1.6% 82.0%

Monuments and Memorials 2,231 1.3% 83.3%

Industrial (other than buildings) 2,146 1.2% 84.5%

Service (other than buildings) 1,661 0.9% 85.4%

Power Development and Distribution 743 0.4% 85.9%

Research and Development (other than Laboratories) 609 0.3% 86.2%

Airfield Pavements 394 0.2% 86.4%

Railroads 238 0.1% 86.6%

Weapons Ranges 140 0.1% 86.6%

Miscellaneous Military Facilities 133 0.1% 86.7%

Space Exploration Structures 79 0.0% 86.8%

All Other 23,294 13.2% 100%

Totals 175,966 100% 100%

Source: GAO Analysis of fiscal year 2012 FRPP data.

Note: According to GSA officials, these figures include about 3,500 Army Corps of Engineers 

structures. The Corps of Engineers has both military and civil-engineering structures.

a

The fiscal year 2012 FRPP also has a category for “Museums” for structures but no civilian agencies 

reported any structures as “Museums.”

Agencies report both structures that are common across federal agencies 

and structures that are more specific to an agency’s mission. As shown in 

table 1, 64 percent of all federal structures in the FRPP are classified as 

one of five specific types: Roads and Bridges; Recreational; Navigation 

and Traffic Aids; Utility Systems; and Parking Structures. Almost all of our 

site visit areas had some of the more commonly reported types of 

structures. According to fiscal year 2012 FRPP data all of the five 

agencies we reviewed reported that they manage 14 types of structures 

in the FRPP. However, while some structures are common across 
Page 7 GAO-14-87 Federal Real Property

agencies, some are more specific to an agency’s particular mission. For 

example, many Federal Aviation Administration (FAA) structures are used 

to control the air traffic in the United States, and Interior’s National Park 

Service (NPS) structures include national monuments like Mount 

Rushmore and the Gateway Arch in St. Louis, Missouri.12

 12The Gateway Arch is one of the structures located at the Jefferson National Expansion 

Memorial, which is reported as having 10 separate structures in 4 categories, none of 

which is reported under monument and memorials.

Figure 1 below 

provides examples of mission-specific structures we visited.
Page 8 GAO-14-87 Federal Real Property

Figure 1: Examples of Mission-Related Federal Structures
Page 9 GAO-14-87 Federal Real Property

Agencies take different approaches to defining and inventorying 

structures making the aggregation of data in the FRPP’s database 

unreliable. Agencies we reviewed defined structures differently leading to 

inconsistencies as to what assets are included in the FRPP, including 

counting some building-like facilities as structures. We also found that the 

agencies we reviewed counted structures differently, provided inaccurate 

location information, and categorized their structures inconsistently, all of 

which limits the usefulness of their data on structures in the FRPP.

Additionally, the agencies we reviewed submitted outdated or incorrect 

information for key data elements, such as the replacement value, annual 

operating costs, and condition. GSA officials that manage FRPP said that 

FRPC chose to provide flexibility in the reporting guidance to account for 

the wide diversity in federal structures, but the FRPP also aggregates the 

data as if they were comparable. Even if this data were useful, FRPC 

reports very little of what it collects from agencies and officials at GSA 

told us that there is low interest in and demand for information on 

structures, a situation that creates few incentives to improve data 

reliability. In addition, OMB officials stated that their focus in recent years 

has been primarily on buildings relative to structures. In prior reports, we 

have stressed the importance of limiting the number of elements to the 

vital few that are considered essential for producing data for decision 

making in light of the costs of collecting this data.

Agencies we reviewed defined a structure differently when inventorying 

their assets. Differing definitions resulted in inconsistent data as different 

types of assets were being labeled as structures across agencies (see 

table 2). Two of the agencies we reviewed—USDA and DOE—did not 

develop a standard definition for a structure. OMB guidelines state that 

agencies should develop detailed guidance necessary for producing 

reliable, consistent data.13 GSA real property officials responsible for the 

FRPP stated that they, in coordination with FRPC, chose to give agencies 

the flexibility to define structures themselves and that FRPP guidance, 

therefore, does not define a structure.

 13Office of Management and Budget, Guidelines for Ensuring and Maximizing the Quality, 

Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies; 

Republication (Washington, D.C.: Feb. 22, 2002).

Inconsistent 

Approaches to 

Tracking Structures 

and Inaccurate 

Information May 

Undermine the 

Reliability of 

Nationwide Data on 

Structures

Agencies Define 

Structures Differently
Page 10 GAO-14-87 Federal Real Property

Table 2: Selected Agencies Definitions of Structures

Agency Definition of structure

DOT A facility that is fixed to the ground without four walls and a roof.

VA Facilities that can be entered by a person, but are not enclosed or lockable or 

facilities that cannot be entered by a person, but provide support to buildings, 

like utility systems.

USDA Officials at each installation determine how to identify structures.

DOE Officials identify structures using the 22 FRPP Real Property Use Types.

Interior All constructed assets that do not meet the definition of a building.

Source: GAO analysis of agency data.

For the agencies we reviewed, these different definitions led to the 

inconsistent identification of similar structures when aggregated across 

agencies, thereby reducing the reliability and accuracy of FRPP data on 

structures. For example, VA has created an “other” category that is 

different from buildings, land, and structures. This category includes 

monuments, statues, and flagpoles—items other agencies report as 

structures in FRPP. While this approach may be legitimate for VA 

purposes as long as it is applied consistently, it will not create consistent 

information government-wide when aggregated in FRPP.14 Because 

USDA and DOE did not define what constituted a structure, the 

categorization of structures may vary by installation, resulting in 

inconsistent information within the agencies. For example, officials at 

DOE’s Lawrence Livermore National Laboratory (LLNL) and the Interior’s 

Bureau of Land Management (BLM) Fort Ord National Monument 

classified the landscaping at a location as a structure in FRPP.15

 14VA officials noted that they are taking steps to re-categorize some assets that were 

previously under the VA’s “other” real property type into other usage codes in one of the 

three FRPP Real Property Types (Land, Building or Structure).

Conversely, officials at DOE’s Argonne National Laboratory did not 

classify landscaping, such as a fountain in front of a building, as a 

structure but considered it part of the building. This approach resulted in 

variation within DOE at the installation level, as well as being inconsistent 

15BLM officials told us beginning in fiscal year 2011, BLM aggregates individual assets 

located at a recreation site, such as the landscaping located at a site in Fort Ord National 

Monument mentioned above, into one data element submittal to the FRPP. They said this 

was done to better represent the true cost to maintaining the site and remove the 

confusion of reporting maintenance costs for minor assets.
Page 11 GAO-14-87 Federal Real Property

with the FRPP guidance, which instructs agencies to report landscaping 

as a structure under “All Other.”

Some facilities we visited were classified by some agencies as structures, 

even though they were similar to buildings (having features such as walls, 

roofs, doors, windows, and air-conditioning systems in some cases).

Figure 2 shows some of these examples.

Figure 2: Examples of Building-Like Structures

GSA officials also said that different approaches to defining structures are 

legitimate under the guidance, but agreed that best practices require a 

consistent agency-wide approach. However, as a starting point to ensure 

that all agencies have a similar understanding of what constitutes a 

structure, the FRPC should update the FRPP guidance to include such a 

definition. Until this action occurs, there will be the increased likelihood 

that agencies will continue to define structures differently, thus negatively 

affecting the reliability of the data being collected.

We found that officials, across agencies we reviewed, also counted 

structures differently, undermining the accuracy of the number of 

structures when totaled nationwide. OMB guidelines state that agencies 

should develop detailed guidance necessary for producing reliable, 

Agencies Count Structures 

Differently
Page 12 GAO-14-87 Federal Real Property

consistent data.16

We found inconsistencies in how officials at different agencies for the 

sites we visited counted the same types of structures. For example, 

officials at the DOE sites we visited aggregated primary roads together 

into singular entries in the FRPP, while officials at the DOT sites we 

visited generally listed each road as separate entries. We also found that 

some officials at the agencies we visited separated features of a structure 

into multiple FRPP entries while other officials included all features as a 

one-structure entry. For example, at the Interior’s Bureau of Reclamation 

(BOR) sites we visited, officials manage large structures, such as power 

plants, dams, and canals, generally grouping various portions of the 

supporting infrastructure related to a main asset together into a single 

entry in the FRPP. Conversely, officials at the FAA sites we visited 

generally disaggregated the components of structures into multiple 

entries in the FRPP because the agency officials track their expenditures 

in multiple systems, and renovations sometimes result in additional 

entries. See figure 3 for an example of how agencies count structures 

differently.

FRPP guidance does not instruct agencies on how to 

count structures, and GSA officials stated that agencies can use different 

approaches as long as they are consistently applied by those agencies.

GSA officials that manage FRPP said that they recognize that flexibility in 

the guidance could result in differences in how agencies designate 

structures, thereby creating issues with how comparable the data are 

across agencies.

 16Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of 

Information Disseminated by Federal Agencies; Notice; Republication.
Page 13 GAO-14-87 Federal Real Property 

Figure 3: Example of How Agency Officials Aggregate and Disaggregate Structures in FRPP

San

Luis

Reservoir

Tracy

Stockton

Interactive Graphic: Rollover the dots for more information. See appendix III for a non-interactive, printer-friendly version.

The Delta-Mendota Canal California, operated by Interior, which reported one 

structure (FRPP Unique ID: R0214004400S) for the entire 117 miles of the 

canal and its related components, including a pumping plant, large water flow 

management gates, and embankment roads and fencing along the canal.

Radio tower at Washington Dulles International Airport in 

Virginia, managed by DOT, which reported 6 structures at this site, 

including the antenna system, raised portion of the tower, original 

tower, cable system, foundation, and the surrounding sidewalk.

Sources: GAO analysis of agency data; FAA and BOR officials; BOR (pumping station and wasteway photographs) and GAO (other photographs).

Modesto

Mendota

5

5

580

132

152

152

33

99

120

4

Note: The rollover dots 

on this map are not 

geographically accurate; 

they show examples of 

infrastructure distributed 

along the canal.

101
Page 14 GAO-14-87 Federal Real Property

We found inconsistencies within agencies when counting structures. For 

example, Interior officials at the sites we visited would both aggregate and 

disaggregate roads. Officials at the BLM site we visited and all four NPS 

sites we visited, listed each road separately, while officials at the BOR 

sites and one of the Interior’s U.S. Fish and Wildlife Service (FWS) sites 

we visited sometimes included roads with related infrastructure, such as 

flood control dikes. Similarly, we found that officials at some of the sites 

we visited, such as the VA and DOE sites, included all the parts of a utility 

system—such as sewage and electrical systems and their components—

into one entry, while officials at other sites, such as NPS’s Prince William 

Forest Park in Virginia separate out certain parts of utility systems into 

multiple entries. Officials from these agencies told us that the decision to 

aggregate or disaggregate structures in the FRPP is dependent on how 

the assets are being managed. For example, Interior officials said that it 

makes sense to combine a road with an asset if it is integral to and 

maintained along with that asset. However, this kind of variation 

undermines the reliability of both the aggregated agency and FRPP data.

We also found that structures without operation and maintenance costs 

may not even be included in some real property databases. For example, 

officials at USDA’s Beltsville Agricultural Research Center (BARC) site 

said structures that existed before the creation of the FRPP do not appear 

in the database unless USDA has spent money to repair or replace them.

As a result, USDA officials estimated that there were many more 

structures located at the BARC site, which is over 100 years old, than the 

125 structures listed in the FRPP. However, FRPP guidance requires the 

inclusion of this information; the FRPP database is intended to be a 

comprehensive real property database of real property assets. Without 

guidance to ensure a common understanding, agencies will likely 

continue to count structures differently thus negatively affecting the 

reliability of the information being collected.

Although all of the agencies we reviewed provided location information for 

their structures, we found that the location data for several of these 

structures were inaccurate, thereby limiting the usefulness of FRPP data. 

FRPP guidance requires that location data be included in the database, 

but allows agencies flexibility in terms of the specificity used to identify the 

FRPP Is Not Reliable for 

Identifying or Determining 

the Location of Structures
Page 15 GAO-14-87 Federal Real Property

location of structures.17 For example, agencies may use the street 

address or the longitude and latitude coordinates. However, the 

Standards for Internal Control in the Federal Government and OMB 

guidance state that management should put in place control mechanisms 

and activities to enable it to enforce its directives and achieve results. In 

addition, GAO and OMB guidance state that one such result should be 

providing data that are consistent and reliable.18

At some of the sites we visited, officials told us they had difficulties 

determining location for larger structures, such as canals, roads, airport 

runways, and irrigation systems, some of which can span several miles 

and even cross county and state lines. In these instances, agency 

officials told us they measure coordinates at one end or at the center of a 

At several sites we 

visited, local agency officials could not specify the structure using the data 

listed in the FRPP database. For example, we found at VA sites that the 

local officials could not confirm that the pieces of infrastructure they 

showed us related to the sites’ utility systems, such as the power 

distribution or water systems, were a part of the structure listed in the 

FRPP database. Even in instances where latitude and longitude 

coordinates were listed in the database, agencies’ officials had difficulties 

finding some structures. For example, local BOR officials at the San Luis 

Dam and Reservoir in California could not locate a recreational structure 

valued at about $96 million. Although there were specific coordinates 

listed in the FRPP for that structure, officials stated that there was nothing 

there that could be considered a recreational structure worth that amount.

While local officials were unable to use the FRPP location information to 

identify this structure, headquarters agency officials explained that this 

structure includes a variety of recreation components, including roads and 

other amenities, located within that geographical area and that the 

latitude and longitude represented a specific point within that area, not a 

specific structure.

 17FRPP guidance also states that for assets that do not have a specific address and when 

there is a security issue associated with reporting the longitude and latitude, agencies 

should report the street address for the main gate or main entrance if the asset is located 

on an installation or campus. If no street address is available, agencies should report a 

zip code; where no zip code is available, agencies should report the nearest city and 

county.

18GAO/AIMD-00-21.3.1; GAO-09-680G; and Guidelines for Ensuring and Maximizing the 

Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies; 

Notice; Republication.
Page 16 GAO-14-87 Federal Real Property

structure, which does not accurately capture the structure’s location. For 

example, at one of the BOR sites we visited, officials said they measure 

the geographic coordinates at the beginning of canals that can span over 

100 miles. Officials from two agencies we reviewed do not use 

geographic coordinates to identify structures’ locations and said 

measuring the coordinates is too challenging and that there was limited 

value for expending resources needed to measure coordinates for 

structures that are already known to the local facility managers at their 

sites. Instead, officials use a central address for the structures they 

manage, which could be a long distance from the actual structure. These 

challenges may result in inaccurate location data on structures in the 

FRPP.

We found inconsistencies with how officials categorize structures that 

may limit the usefulness of the data. OMB guidelines state that agencies 

should develop detailed guidance necessary for producing reliable, 

consistent data. As stated above, FRPP guidance categorizes structures 

into 22 different types and includes brief descriptions of the types of 

structures for each category. The guidance allows similar structures to be 

categorized differently. For example, FRPP guidance describes three 

different categories for which dams could fit, such as power development 

and distribution, reclamation and irrigation, and flood control and 

navigation. This categorization means that these dams could be included 

in these FRPP categories along with other non-dam structures (such as 

power plants, canals, or docks). We found that five different dams in five 

locations, all of which served different purposes were categorized 

differently in the FRPP database (see fig. 4 below). This makes it even 

more difficult to make decisions based upon numbers of structures in the 

categories because structures comprise such varied assets, with some 

similar type assets, such as dams, reported in different categories.

Agencies Categorize 

Structures Differently
Page 17 GAO-14-87 Federal Real Property

Figure 4: Examples of Similar Structures with Different Purposes

Officials from sites we visited from three of the five agencies we reviewed 

told us that they have difficulty identifying the appropriate category for 

structures because the agencies’ structures vary and have unique 

characteristics. As a result, these agencies frequently use the FRPP 

catchall, “All Other,” category when their structures do not fit within the 

other 21 categories; civilian agencies used the “All Other” category 

23,294 times in fiscal year 2012 elevating it to the third largest category, 

accounting for 13.2 percent of structures listed. For example, during our 

site visits, officials showed examples of structures that were categorized 
Page 18 GAO-14-87 Federal Real Property

as “All Other” in the FRPP database, such as fences, sidewalks and 

paths, observation decks and platforms, lagoons, and signs. These 

structures are legitimately reported in the “All Other” category, but the 

FRPP database does not allow for further disaggregation limiting the 

usefulness of the category for identifying the type of the structure. GSA 

officials recognized that that the 22 categories of structures in the FRPP 

do not capture the wide variety of different structures agencies operate. 

However, the GSA officials said that because of a lack of detail as to what 

the agencies include in the “All Other” category, they are unsure of what 

category additions or changes they should make. These officials 

acknowledged that it would be difficult to develop a comprehensive list of 

categories. Wide use of the “All Other” category reduces the usefulness 

of FRPP for managing structures by limiting the amount of detail that the 

database can have.

Key FRPP elements for structures—replacement value, annual operating 

costs, and condition—are not reliable because some of the data 

submitted by agencies we reviewed are outdated or incorrect.19

Although the agencies we reviewed recorded replacement values for their 

structures as required by the FRPP guidance, the replacement values 

were not always accurate, thereby limiting data’s usefulness.

GSA 

officials said that while they have taken steps to improve data quality, 

they ultimately rely on the agencies, which are required to certify that the 

data they transmit to FRPP are complete and reliable. Specifically, GSA 

officials said that agency submissions are not altered in any way once 

submitted to FRPP, meaning that any inaccuracies originated at the 

agency level.

20

 19These are similar to our 2012 findings related to the performance data in FRPP for 

buildings. See 

As stated 

earlier, the Standards for Internal Control in the Federal Government and 

OMB guidance state that management should put in place control 

mechanisms and activities to enable it to enforce its directives and 

GAO-12-645.

20FRPP guidance states that the intent is for agencies to define their own guidance and 

regulations for implementing the replacement value formula found in the guidance. It also 

states that GSA and DOD have published cost guidance that can be used by other 

agencies. Officials from DOT and local officials from one USDA site we visited told us they 

use the DOD’s Facilities Pricing Guide for estimating the replacement value for certain 

structures.

Key Data Elements in 

FRPP for Structures Are 

Not Reliable

Replacement Value
Page 19 GAO-14-87 Federal Real Property

achieve results. GAO and OMB guidance state that one such result 

should be providing data that are consistent and reliable. Without this 

guidance, agencies cannot ensure that they are collecting and reporting 

consistent and reliable data on their structures internally, data that are 

then submitted to FRPP. For example, officials told us that replacement 

values in the FRPP seemed too high or too low, and other officials told us 

the replacement value did not match or come close to matching the 

replacement value listed in agencies’ own property-management 

databases (see fig. 5). However, because local agency officials were 

often not the ones entering data into the agencies’ real property 

databases or entering the data into the FRPP database, they could not 

explain why there were differences between FRPP and their agency’s 

own property databases for these structures.

To calculate the replacement value for all structures annually as required 

by FRPP guidance, the agencies we reviewed reported using a number of 

different methods, including adjusting cost models designed for buildings 

to structures, escalating the original cost of constructing structures, and 

relying on estimates made by local officials and experts. While there are 

cost-estimating models available for calculating the replacement value of 

a building, there are no standard estimation methods available for all 

types of structures. Officials from Interior, VA, and DOE said that the lack 

of standard cost-estimating models for structures makes it more 

challenging and could introduce variation into the estimates as agencies 

develop their own models.
Page 20 GAO-14-87 Federal Real Property

Figure 5: Examples of Inconsistent and Inaccurate Replacement Values for 

Structures
Page 21 GAO-14-87 Federal Real Property

Although the agencies we reviewed identified annual operating costs for 

structures as required by FRPP guidance, we found that these costs were 

not always accurate, thereby reducing the consistency and reliability of 

FRPP data.21

 21FRPP guidance states this should consist of the following full year costs: recurring 

maintenance and repair costs, utilities, cleaning and/or janitorial costs, and roads/grounds 

expenses.

As stated earlier, the Standards for Internal Control in the 

Federal Government and OMB guidance state that management should 

put in place control mechanisms and activities to enable it to enforce its 

directives and achieve results. In addition, GAO and OMB guidance state 

that one such result should be providing data that are consistent and 

reliable. Officials from one USDA site we visited said that none of the 

annual operating costs listed in the FRPP are accurate because the 

calculation is based on a standard formula of 1 percent of the 

replacement value, which does not reflect the structures’ true costs. 

USDA officials agreed that their approach to calculating the operating 

costs did not produce accurate results at the individual structure level, but 

they said that USDA does not have the capacity to collect operating cost 

data for individual structures. Although FRPP guidance does not address 

the issue, GSA officials recognize that agencies must estimate the 

operating costs if they do not have the capacity to track operating costs 

for individual structures. We also found instances where local officials at 

sites we visited told us the annual operating costs listed in the FRPP are 

inaccurate. For example, officials at several of the sites we visited could 

not explain why some structures had zero operating costs listed in the 

FRPP or why some of the FRPP listed costs were higher compared to the 

amount of maintenance performed related to the structure. However, 

headquarters officials with VA said that structures listed as having zero 

operating costs, such as the committal shelter at the Quantico (VA) 

National Cemetery shown in Figure 6, are included in the operating costs 

under the associated building or land entries in FRPP.

Annual Operating Costs
Page 22 GAO-14-87 Federal Real Property

Figure 6: Example of Zero Annual Operating Costs for a Structure, a Committal 

Shelter at Quantico (VA) National Cemetery, Virginia

Additionally, we found that some agencies reported the costs of 

structures operated and maintained by other entities. For example, 

officials at the BOR sites we visited in Arizona and California reported 

annual operating costs of $1.9 million and $3.8 million attributed to the 

Mark Wilmer Pumping Plant and the Delta-Mendota Canal, which 

includes the Tracy C.W. “Bill” Jones Pumping Plant. However, these two 

assets are fully managed and operated by state and district entities and 

are fully funded from the revenues generated from the sale of water and 

electricity. Interior officials told us these costs are to be reported because, 

as a term-limited management agreement, future responsibility for 

maintenance is still a federal liability, and the FRPP guidance instructs 

agencies to report annual operating costs for structures managed by 

other entities. However, the actual costs paid by the federal government 

on an annual basis may be overestimated in the FRPP, because 

according to local Interior officials, a portion of those costs are paid from 

revenues collected by the state and district entities. We also found that 
Page 23 GAO-14-87 Federal Real Property

USDA reported the annual operating costs for a bullet trap on a weapons 

range located at BARC, but the bullet trap is fully maintained and 

operated by a separate federal entity. USDA officials said that they were 

following FRPP guidance as they understood it.

Officials from the agencies we reviewed also noted that it is often 

challenging to calculate annual operating costs for structures and that 

different approaches may be used for different structures within agencies. 

For example, agency officials at some sites we visited told us they use 

associated costs—such as labor, utilities, and maintenance—to report 

annual operating costs. However, officials from DOE and VA sites that we 

visited told us that these data can be difficult to calculate at the individual 

asset level. Instead, they apportion certain types of costs, such as for 

electricity, evenly across certain structures. Different approaches within 

agencies undermine the consistency and, consequently, the reliability of 

the operating-cost data for these agencies.

Although the agencies we reviewed reported the condition of their 

structures as required by FRPP guidance, the FRPP data on the 

condition of these structures were not always accurate. According to 

FRPP guidance, condition index is a general measure of the constructed 

asset’s condition and is calculated using the ratio of repair needs to the 

replacement value.22 We found numerous examples at the sites we 

visited where the listed FRPP condition did not match the observed 

condition of the structure. For example, we found a parking lot and a road 

at one FAA site that had a condition index listed as zero in the FRPP 

(which, according to FRPP guidance, represents the worst possible 

condition for the asset), and we found cooling towers at DOE’s LLNL that 

had a condition index listed as 100. However, we did not find these 

structures to be in the most critical or excellent conditions. Officials from 

Interior, VA, and DOE told us they will also sometimes submit zero-dollar 

repair needs to FRPP for some of their structures that they no longer use 

and may be ultimately disposed of, even though the structure may be in 

disrepair, because it allows the agencies to prioritize funds for other 

assets.23

 22Repair needs include the amount necessary to ensure that a constructed asset is 

restored to a condition substantially equivalent to the originally intended and designed 

capacity, efficiency, or capability.

However, this can result in the inaccurate reporting of the 

23VA officials stated that structures that are in the disposal process do not go through VA’s 

condition assessment process as repair needs are no longer necessary.

Condition Index
Page 24 GAO-14-87 Federal Real Property

structure’s conditions in the FRPP because the condition index 

calculation relies on the amount of repair needs. For example, agency 

officials responsible for FRPP data at the FWS’s Don Edwards San 

Francisco National Wildlife Refuge calculated the condition index for a 

historic cannery as 100, which would indicate the best condition 

reportable. However, as shown in figure 7, the condition index of the 

structure does not match its true condition. Agency officials told us the 

reason the condition is listed as 100 is because they entered zero dollars 

needed for repair to free funds for other structures, as this structure is not 

open to the public and does not currently serve a purpose on the FWS 

property. Also, officials told us if there is no intent to repair or maintain a 

structure, there is no reason to spend limited resources to complete a 

comprehensive condition assessment. Officials from NPS’s Golden Gate 

National Recreation Area told us that a historic battery built for use during 

World War I and valued at almost $200 million, had about $450,000 in 

deferred maintenance, but we found its condition listed as 100 in the 

FRPP. According to officials at USDA’s BARC site, all of the listed 

conditions for the structures we viewed at the site were inaccurate. These 

officials could not explain why the condition index, calculated by an 

independent contractor, was the same for all but one of the structures, 

and they agreed these metrics were not reflective of the structures’ true 

conditions. As stated above, the FRPC has made changes for 2013 by 

having the FRPP automatically calculate the condition index using the 

formula stated above as well. While the formula has not changed, the 

FRPC has also revised FRPP guidance to require that agencies report all 

the repair needs, including the repairs agencies do not plan to make. 

OMB staff told us they hope this will prevent agencies from submitting 

inflated conditions.
Page 25 GAO-14-87 Federal Real Property

Figure 7: Examples of the Condition of Interior’s Fish and Wildlife Service’s Historic Cannery at Don Edwards San Francisco 

National Wildlife Refuge in California

Even if data on federal structures were reliable, FRPC reports very little of 

what it collects from agencies. Internal control standards for federal 

executive branch agencies require that agencies have relevant 

information for decision-making and external-reporting purposes. For 

fiscal year 2012, public access to FRPP data are limited to a 23-page, 

high-level summary report for all 361,318 federal buildings, 485,866 

federal structures, and about 44 million acres of federal land. The highlevel summary report includes aggregated data on 5 of the 23 elements 

that agencies are required to submit. This raises questions about the 

importance of aggregating structures data government-wide. As stated 

earlier, in previous reports we have stressed the importance of limiting the 

number of elements to the vital few that are considered essential for 

producing data for decision making in light of the costs of collecting this 

data. This will help agencies focus their limited resources on ensuring that 

those vital elements are reliable. In addition, GSA and OMB officials said 

there is low interest in and demand for government-wide information 

specifically related to structures, resulting in little incentive to make 

improvements. They said the majority of requests for information from 

users of FRPP data—the administration, the Congress, and the public—

are related to buildings, not structures, so they have focused their efforts 

at improving and more extensively evaluating FRPP data related to 

buildings. Based on conversations we had with OMB staff, FRPP building 

data may be of more interest than structures because buildings that are 

occupied by federal workers and visited by the public have safety, 

security, and resale factors that do not generally exist for structures. 

Incentives to Improve 

FRPP Data on Structures 

Are Limited Due to Low 

Demand for and Utility of 

the Data
Page 26 GAO-14-87 Federal Real Property

Buildings also can have value to the private sector, making them targets 

for sale, while structures are less likely to have commercial value and 

(like some federally-owned buildings) could also be located inside a large 

federal land area. Figure 8 illustrates how some structures likely have no 

private-sector value.

Figure 8: Structures That Likely Have Little Private-Sector Value

While OMB staff acknowledged that the FRPP’s data on structures have 

reliability issues and that there is lower demand for information on 

structures compared to buildings, they also said that structures represent 

investments of taxpayer money and as such agencies should continue to 

track their structures because the data are valuable to agency officials. 

Agency officials consistently said that they would continue tracking their 

structures even if they did not submit it annually to the FRPP. However, 

some agencies might not track the same elements. For example, FAA 

officials said that the agency only tracks the congressional district of each 

of their structures because it is a required element in the FRPP guidance.
Page 27 GAO-14-87 Federal Real Property

We found that agencies generally face similar challenges in managing 

structures as they do in managing buildings. All agency officials we spoke 

with stated that most challenges centered on prioritizing resources to 

maintain structures, ensuring the safety and security of structures, and 

disposing of excess structures.

Officials from all the agencies we spoke with stated that prioritizing 

resources is their primary challenge to managing structures. For example, 

Interior officials stated that their major challenge is to maintain Interior’s 

mission critical assets as the current funding levels are less than half of 

the minimum they consider necessary to sustain acceptable conditions.

We have previously developed criteria for addressing real property 

maintenance backlogs based on National Academy of Sciences reports 

on maintenance and repair of federal facilities.24 Our criteria includes, 

among other things, setting priorities among the outcomes to be achieved 

from maintenance activities, identifying critical assets to invest in, and 

analyzing tradeoffs and optimizing results from competing investments in 

maintenance. Interior officials told us they provide department-wide 

guidance for capital investment strategies. Following this guidance, for 

example, NPS has developed an investment matrix that combines 

mission criticality and historic importance with the amount of deferred 

maintenance to determine which structures to invest in first. FAA officials 

in one FAA region are using their own unique database to determine the 

maintenance costs for structures to prevent failure of mission critical 

structures that support the national airspace. FAA is currently undertaking 

an agency-wide initiative to address their deferred maintenance needs for 

these structures.

 24National Academy of Sciences, Predicting Outcomes from Investments in Maintenance 

and Repair for Federal Facilities (Washington, D.C.: 2012).

Agencies Face 

Similar Challenges in 

Maintaining, 

Securing, and 

Disposing of 

Structures as They 

Do for Buildings

Prioritization of Resources 

for Maintaining Structures 

Is Difficult
Page 28 GAO-14-87 Federal Real Property

Agency officials at the sites we visited stated some security and safety 

challenges were related to the location and condition of structures for 

which they were responsible. One of the security concerns mentioned by 

some NPS and BLM officials was that some structures were spread out 

over the park or other federal land area making it challenging to ensure 

their security. For example, the NPS’ Golden Gate National Recreational 

Area has over 500 structures spread out over 60 miles around the San 

Francisco Bay area, and BLM’s Fort Ord National Monument has 67 

structures spread out over 7,200 acres. NPS officials also mentioned that 

there are challenges in securing nationally significant structures in 

National Parks while encouraging the public to visit those structures and 

working to provide a favorable experience during their visit. Other 

structures present security and safety challenges different from buildings.

NPS officials stated that some structures may be in rugged terrain, have 

multiple points of approach, all making security and safety more 

challenging than for buildings where security and safety features can be 

built in and access controlled more easily. The BOR’s 117-mile long 

Delta-Mendota Canal in California, which provides critical water resources 

to southern California, presents a security challenge due to its long length 

through sparsely populated areas as well as a safety challenge as parts 

of the canal are open to the public (see fig. 9). To mitigate the safety risk 

presented by the canal’s swiftly flowing waters, safety lines have been 

installed to help people climb out of the canal if they fall in.

Location and Condition of 

Some Structures Present 

Security and Safety 

Challenges
Page 29 GAO-14-87 Federal Real Property

Figure 9: Examples of Security and Safety Challenges Presented by the Long Length of and the Swiftly Flowing Water in the 

Delta-Mendota Canal in California

Federal agencies we reviewed have structures that they are not utilizing.

However, agencies struggle to dispose of excess structures.25

 25

In some 

cases, the agencies may just leave the obsolete structures. For example, 

many structures at the USDA’s Agricultural Research Service’s Beltsville 

research facility in Maryland are no longer used but remain in place on 

the 6,700 acre site. Figure 10 shows a water tower on the site that has 

been unused for years and that is slowly being recaptured by nature.

GAO-12-645. Section 102 of title 40 of the U.S. Code defines excess property as 

“property under the control of a federal agency that the head of the agency determines is 

not required to meet the agency’s needs or responsibilities.” Agencies may also 

designate a property as underutilized defined as “an entire property or portion thereof, with 

or without improvements, which is used:(a) irregularly or intermittently by the accountable 

Executive agency for current program purposes of that agency; or (b) For current program 

purposes that can be satisfied with only a portion of the property.” 41 C.F.R. §102-75.50. 

Agencies Have Unneeded 

Structures, but 

Uniqueness, Location, and

Resources Complicate 

Disposal
Page 30 GAO-14-87 Federal Real Property

Figure 10: Unused Water Tower at USDA’s Beltsville Facility, Maryland

Officials at NPS’s San Francisco Maritime National Historic Park in 

California determined that one of its larger ships was excess and will 

scrap it offsite. In a different case, NPS implemented a creative solution 

to obsolete structures by turning the historic batteries that protected the 

San Francisco harbor during World Wars I and II into tourist attractions 

and warehouses. Other structures, such as DOE’s particle accelerators, 

are unique to an agency’s mission; even if DOE determined the 

accelerators to be excess property, they would likely have no use outside 

of that research mission.

Four of five agency officials we spoke with also stated that the remote 

location of many structures or their location on large campuses of federal 

land made disposal impractical. Many of the sites we visited were either 

located on large or integrated parcels of federal land (such as a National 

Park or the grounds of a VA hospital) or were spread out over long 

distances (such as canals and reservoirs). For example, Interior officials 

said that the vast majority of the structures are located on trust 
Page 31 GAO-14-87 Federal Real Property

stewardship lands, which, by law according to Interior, cannot be divested 

through conveyance or sale and that congressional approval is frequently 

required. They also said before any possible demolition could occur, 

historic status and environmental surveys must be completed, adding to 

the difficulties and costs of disposal. In addition, structures operated by 

FAA may be located on airport property or in remote areas on leased land 

with clauses that require FAA to restore the land to its original condition, 

increasing the disposal costs of excess structures.

Federal agencies are required to report 23 separate elements for every 

one of their structures to FRPP every year, but the data have two types of 

reliability problems. First, at the most basic level, some of the data 

agencies submit on their structures are incorrect, undermining agencies’

ability to manage their structures and the reliability of the data in FRPP.

Agencies must improve their data quality in accordance with OMB’s 

guidelines in order to document performance and support decision 

making. Second, even if agencies effectively apply the OMB guidance, 

the government-wide data will continue to face reliability problems 

because of the flexibility built into FRPP guidance on how agencies track 

key elements, such as defining and counting structures. FRPC chose not 

to establish a clear definition for structures, but a clear demarcation 

between buildings and structures would be useful for ensuring that 

FRPP’s data related to buildings are complete and that agencies do not 

use the flexibility they have in defining structures to include assets that 

are more appropriately considered buildings. Better defining structures 

alone, however, will not change the fact that reasonable differences in 

how agencies track their structures create inconsistencies when FRPP 

data are aggregated government-wide. For vital information, it would be 

worth the time, resources, and effort needed to harmonize agency 

approaches. However, while agencies need to track structures for their 

own purposes, it is unclear if it is necessary to aggregate the information 

government-wide. GSA and OMB officials said that demand for structures 

information is low, and FRPC only summarizes selected elements of the 

data annually, and most of those elements relate to buildings not 

structures.

To better ensure the quality of both the more detailed data that agencies 

collect on their structures and the summary information submitted in the 

FRPP, we recommend that the Director of OMB, in collaboration with 

FRPC, develop guidance to improve agencies’ internal controls to 

produce consistent, accurate, and reliable data on their structures.

Conclusions

Recommendations for 

Executive Action
Page 32 GAO-14-87 Federal Real Property

To better ensure the quality of the data in FRPP and focus agency 

resources to consistently account for structures, we recommend that the 

Administrator of GSA, in collaboration with the FRPC, take the following 

two actions:

• Issue guidance to federal agencies clarifying the definition of 

structures. This clarification should ensure that building-like structures 

are identified as buildings.

• Assess the feasibility of limiting the data elements agencies would be 

required to submit for structures submitted to the FRPP.

We sent a copy of this report to the Director of the Office of Management 

and Budget; the Administrator of the General Services Administration; 

and the Secretaries of Agriculture, Energy, the Interior, Transportation, 

and Veterans Affairs for their review and comment. OMB generally 

agreed with our findings and recommendation and made technical 

comments, which we incorporated as appropriate. GSA agreed with our 

recommendations and provided its action plan for addressing the 

recommendations. GSA’s response is reprinted in appendix II. USDA, 

DOE, Interior, and VA provided technical comments, which we 

incorporated as appropriate. DOT did not have any comments on the 

report.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Director of the Office 

of Management and Budget; the Administrator of the General Services 

Administration; and the Secretaries of Agriculture, Energy, the Interior, 

Transportation, and Veterans Affairs. In addition, this report will be 

available at no charge on GAO’s website at http://www.gao.gov.

Agency Comments
Page 33 GAO-14-87 Federal Real Property

If you or your staff have any questions, please contact me at (202) 512-

2834 or at wised@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made key contributions to this report are 

listed in appendix IV.

David J. Wise

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-14-87 Federal Real Property

Our objectives were to determine (1) the scale and scope of federallyowned or leased structures, (2) how federal agencies track and 

categorize federal structures, and (3) the extent to which the challenges 

the federal agencies face in managing buildings also apply to structures.

To address these objectives, we reviewed pertinent laws, regulations, 

policies, and other documents related to federal real property 

management. The primary source of government-wide federal real 

property information is the Federal Real Property Council’s (FRPC) 

Federal Real Property Profile (FRPP). We reviewed guidance from the 

FRPC regarding structures, including the Guidance for Real Property 

Inventory Reporting for the FRPP. We obtained FRPP summary data 

from fiscal years 2010 and 2012, the most recent data available, for 

structures owned and operated by the federal government.

We recently reported that the FRPC has not followed data collection 

practices that would help them collect FRPP data in a way that is 

sufficiently consistent and accurate to make property management 

decisions.1 We recommended that GSA develop a plan to improve FRPP 

data. GSA agreed with the recommendation but has not yet finished 

implementing it. Nonetheless, we also found that the FRPP can be used 

in a general sense to track federal real property. As such, for this report 

and a similar report using FRPP data, we have determined that FRPP 

data were sufficiently reliable for limited purposes, such as: identifying 

agencies within our scope, selecting site visit locations, summarizing 

agency-level statistics for structures, and to compare against agency 

source data on structures for our selected agencies.2

We identified five civilian real property-holding agencies for our review: 

the Departments of Agriculture (USDA), Energy (DOE), the Interior 

(Interior), Transportation (DOT), and Veterans Affairs (VA). On the basis 

of the latest FRPP summary data for federal structures available, these 

five agencies reported being responsible for approximately 83 percent of 

all federal civilian structures. We used the following criteria to select these 

agencies as reported to the FRPC for inclusion in the FRPP: number of 

structures, diversity in types of structures, and high replacement value 

and operations and maintenance costs. These agencies gave us a 

 1

GAO-12-645.

2

GAO, Federal Real Property: Strategic Partnerships and Local Coordination Could Help 

Agencies Better Utilize Space, GAO-12-779 (Washington, D.C.: July 25, 2012).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-14-87 Federal Real Property

diverse array of structures to review, a high reported dollar value for 

replacement value (a reported combined $5.9 billion of operating costs 

per year) and annual operating costs and a mix of challenges, such as 

sensitive security or critical systems used in operating a large hospital.

We excluded the Department of Defense (DOD) agencies because GAO 

has completed other engagements focused exclusively on DOD real 

property. We excluded the Department of State as most of its real 

property holdings, including structures, are outside of the United States.

We excluded the Department of Homeland Security, an agency that is 

responsible for more structures than DOE or VA, from our agency 

selection as some structures could be security sensitive and we 

determined that our other selected agencies had a good representation of 

the different kinds of structures in the FRPP.

To determine to the scale and scope of federal structures, we obtained 

and analyzed FRPP data submissions and other real property data from 

the five selected agencies; interviewed real property officers at these 

agencies; visited sites where the agencies had structures; interviewed 

Office of Management and Budget and General Services Administration 

staff about the FRPP data for structures; and reviewed FRPC guidance 

and other documents related to the agencies’ real property data and the 

FRPP database. We obtained the agencies’ FRPP data submissions for 

structures for fiscal year 2012. In addition, for select data elements and 

for structures we saw during our site visits, we obtained real property data 

for structures from the source databases that each agency uses to 

generate its annual FRPP submissions. We obtained source system data 

to compare what was in the FRPP against the data that were in the 

agency’s own databases for those structures. As we have determined in 

prior reports on FRPP data, FRPP submissions can only be changed by 

the agency submitting the data. As a result, we believe that the FRPP 

submissions obtained from the agencies match the data contained in the 

FRPP database. In addition, for select data elements, we obtained real 

property data from the source databases that each agency uses to 

generate its annual FRPP submissions. We obtained source system data 

to get information on description, replacement value, operational costs, 

location, and condition of selected structures.

We posed questions to senior real property officers at the five agencies 

about their processes for collecting and calculating data for structures. To 

gather detailed examples of structures and to learn about the processes 

by which data on such properties are collected or calculated and then 

submitted to the FRPP database, we visited sites where the five agencies 

we selected had structures. We selected these sites using information 
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-14-87 Federal Real Property

from the agencies’ FRPP submissions. Using the most recent FRPP 

submissions we had at the time for each agency, we selected a nonprobability sample of sites. Because this is a non-probability sample, 

observations made at these site visits do not support generalizations 

about other properties described in the FRPP database or about the 

characteristics or limitations of other agencies’ real property data for 

structures. Rather, the observations made during the site visits provided 

specific, detailed examples of issues that were described by agency 

officials regarding the way agencies collect and calculate data for

structures. We focused on sites clustered around four cities: Washington, 

D.C.; Chicago, Illinois; Los Angeles, California; and San Francisco, 

California. This strategy afforded both geographic diversity and balance 

among our selected agencies while also accommodating time and 

resource constraints. In selecting sites and buildings in and around these 

four cities, we took into account the following factors:

• We prioritized sites that had multiple selected agency sites where a 

high concentration of structures was present. This allowed us to see 

more properties in a limited amount of time.

• We prioritized the selection of as many different types of structures 

(as defined in the FRPP) as possible.

• We also selected sites with high replacement values, high operations 

and maintenance costs, exceptionally low replacement values or 

operations and maintenance costs, those reported to be in good and 

poor condition, and structures registered as historic.

We visited at least two sites for each selected agency across our four 

site-visit areas. In all, we selected 24 sites. Whereas we selected sites 

based in large part on the numbers and kinds of structures present, the 

structures we saw at each site depended on additional factors. At some 

sites, there were too many structures to see them all, given our limited 

time at each site. In those circumstances, we prioritized structures that 

were close to one another to see as many structures as we could in the 

time we had, those structures with high or exceptionally low reported 

replacement values or high operation and maintenance costs, and 

different structure types as classified by the agency in FRPP. At several 

sites, local real property officials identified other structures that we toured 

and analyzed.

Prior to each site visit, we analyzed the FRPP data submissions for the 

latest year available, and developed questions about the data 

submissions for local property managers. We also contacted the local 

property managers to answer those questions and to solidify the exact 
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-14-87 Federal Real Property

structures we would see at each location. During our site visits, we 

interviewed local property managers and compared what we observed at 

each structure with the FRPP data for that structure, and we took 

photographs of the structures. In addition to questions about individual 

properties, we questioned the local officials about the kind of data they 

collect on the properties, how they collect that data, and how that data

differed from the FRPP data we had for the structures at the location.

To identify the challenges facing federal agencies in managing structures, 

we analyzed agency property management reports, strategic plans, and 

FRPP reports along with statements from agency officials both at agency 

headquarters and at sites we visited about their challenges. We 

compared these challenges to those we had identified in our reports 

about federal real-property management challenges for buildings to 

determine how similar the agency’s challenges for buildings were to those 

for managing structures.

We conducted this performance audit from January 2013 to January 2014 

in accordance with generally accepted government auditing standards.

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the General 

Services Administration

Page 38 GAO-14-87 Federal Real Property

Appendix II: Comments from the General 

Services Administration
Appendix II: Comments from the General 

Services Administration

Page 39 GAO-14-87 Federal Real Property
Appendix III: Full Text for Figure 3 on How 

Agencies Aggregate and Disaggregate 

Structures in FRPP

Page 40 GAO-14-87 Federal Real Property

Appendix III: Full Text for Figure 3 on How 

Agencies Aggregate and Disaggregate 

Structures in FRPP
Appendix III: Full Text for Figure 3 on How 

Agencies Aggregate and Disaggregate 

Structures in FRPP

Page 41 GAO-14-87 Federal Real Property
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 42 GAO-14-87 Federal Real Property

David J. Wise, (202) 512-2834 or wised@gao.gov

In addition to the named contact above, Keith Cunningham (Assistant 

Director), Melissa Bodeau, Anthony Costulas, Anne Doré, Kathleen 

Gilhooly, Greg Hanna, Robert Heilman, Joshua Ormond, Sara Ann 

Moessbauer, and Sandra Sokol made key contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(542214)
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